Introduction
Welcome to Way To Go’s
privacy policy.
Way To Go respects
your privacy and is committed to protecting your personal data. This
privacy policy will inform you as to how we look after your personal
data when you visit our website (regardless of where you visit it
from) and tell you about your privacy rights and how the law protects
you.
This privacy policy is provided in a layered
format so you can click through to the specific areas set out below.
Please also use the Glossary to understand the meaning of some of the
terms used in this privacy policy.
1. IMPORTANT INFORMATION
AND WHO WE ARE
2. THE DATA WE COLLECT
ABOUT YOU
3. HOW IS YOUR PERSONAL
DATA COLLECTED?
4. HOW WE USE YOUR
PERSONAL DATA
5. DISCLOSURES OF YOUR
PERSONAL DATA
6. INTERNATIONAL
TRANSFERS
7. DATA
SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you
information on how Way To Go
collects and processes your personal data through your use of this
website, including any data you may provide through this website when
you purchase a product or service.
This website is not intended for children and
we do not knowingly collect data relating to children.
It is important that you read this privacy
policy together with any other privacy policy or fair processing
policy we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how
and why we are using your data. This privacy policy supplements other
notices and privacy policies and is not intended to override them.
Controller
Way To Go is the controller and
responsible for your personal data (collectively referred to as Way
To Go, "we", "us" or
"our" in this privacy policy).
We have appointed a data privacy manager who
is responsible for overseeing questions in relation to this privacy
policy. If you have any questions about this privacy policy,
including any requests to exercise your legal rights, please contact
the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy
policy or our privacy practices, please contact our data privacy
manager in the following ways:
Full name of legal entity: Way To Go
Email address: info@mywaytogo.io
Postal address:
You have the right to make a complaint at any
time to the Information Commissioner's Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns
before you approach the ICO so please contact us in the first
instance.
Changes to the privacy policy and your duty
to inform us of changes
We keep our privacy policy under regular
review.
It is important that the personal data we hold
about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
Third-party links
This website may include links to third-party
websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or
share data about you. We do not control these third-party websites
and are not responsible for their privacy statements. When you leave
our website, we encourage you to read the privacy policy of every
website you visit.
The data we collect about you
Personal data, or personal information, means
any information about an individual from which that person can be
identified. It does not include data where the identity has been
removed (anonymous data).
We may collect, use, store and transfer
different kinds of personal data about you which we have grouped
together as follows:
Identity Data
includes first name, maiden name, last name, username or similar
identifier, title, date of birth and gender.
Contact Data
includes billing address, delivery address, email address and
telephone numbers.
Financial Data
includes bank account and payment card details.
Transaction Data
includes details about payments to and from you and other details of
products and services you have purchased from us.
Technical Data
includes internet protocol (IP) address, browser type and version,
time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices
you use to access this website.
Profile Data includes
purchases or orders made by you, your interests and preferences.
Usage Data
includes information about how you use our website, products and
services.
Marketing and Communications Data includes
your preferences in receiving marketing from us and your
communication preferences.
From time to time we may also collect, use and
share Aggregated Data
such as statistical or demographic data for any purpose. Aggregated
Data could be derived from your personal data but is not considered
personal data in law as this data will not
directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or
connect Aggregated Data with your personal data so that it can
directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy
policy.
We do not intentionally collect any Special
Categories of Personal Data about
you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political
opinions, trade union membership, information about your health, and
genetic and biometric data). Nor do we collect any information about
criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law,
or under the terms of a contract we have with you, and you fail to
provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example,
to provide you with goods or services). In this case, we may have to
cancel a product or service you have with us, but we will notify you
if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from
and about you including through:
Direct interactions.
You may give us your Identity, Contact and Financial Data by filling
in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:
apply for our products or services;
request marketing to be sent to you; or
give us feedback or contact us.
Automated technologies or interactions.
As you interact with our website, we will automatically collect
Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies and other similar
technologies. Please see our cookie policy for further details.
Third parties or publicly available
sources. We will receive personal
data about you from various third parties and public sources as set
out below:
Technical Data from the following parties:
Contact, Financial and Transaction Data from
providers of technical, payment and delivery services.
Identity and Contact Data from publicly
available sources such as Companies House.
How we use your personal data
We will only use your personal data when the
law allows us to. Most commonly, we will use your personal data in
the following circumstances:
Where we need to perform the contract, we are
about to enter into or have entered into with you.
Where it is necessary for our legitimate
interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
Where we need to comply with a legal
obligation.
Click here
to find out more about the types of lawful basis that we will rely on
to process your personal data.
Generally, we do not rely on consent as a legal
basis for processing your personal data.
Purposes for which we will use your personal
data
We have set out below, in a table format, a
description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified
what our legitimate interests are where appropriate.
Note that we may process your personal data for
more than one lawful ground depending on the specific purpose for
which we are using your data. Please contact us if you need details
about the specific legal ground we are relying on to process your
personal data where more than one ground has been set out in the
table below.
|
Purpose/Activity
|
Type
of data
|
Lawful
basis for processing including basis of legitimate interest
|
|
To
register you as a new customer
|
(a)
Identity
(b)
Contact
|
Performance
of a contract with you
|
|
To
process and deliver your order including:
(a)
Manage payments, fees and charges
(b)
Collect and recover money owed to us
|
(a)
Identity
(b)
Contact
(c)
Financial
(d)
Transaction
(e)
Marketing and Communications
|
(a)
Performance of a contract with you
(b)
Necessary for our legitimate interests (to recover debts due to
us)
|
|
To
manage our relationship with you which will include:
(a)
Notifying you about changes to our terms or privacy policy
(b)
Asking you to leave a review or take a survey
|
(a)
Identity
(b)
Contact
(c)
Profile
(d)
Marketing and Communications
|
(a)
Performance of a contract with you
(b)
Necessary to comply with a legal obligation
(c)
Necessary for our legitimate interests (to keep our records
updated and to study how customers use our products/services)
|
|
To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data)
|
(a)
Identity
(b)
Contact
(c)
Technical
|
(a)
Necessary for our legitimate interests (for running our business,
provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or
group restructuring exercise)
(b)
Necessary to comply with a legal obligation
|
|
To
use data analytics to improve our website, products/services,
marketing, customer relationships and experiences
|
(a)
Technical
(b)
Usage
|
Necessary
for our legitimate interests (to define types of customers for our
products and services, to keep our website updated and relevant,
to develop our business and to inform our marketing strategy)
|
|
To
make suggestions and recommendations to you about goods or
services that may be of interest to you
|
(a)
Identity
(b)
Contact
(c)
Technical
(d)
Usage
(e)
Profile
(f)
Marketing and Communications
|
Necessary
for our legitimate interests (to develop our products/services and
grow our business)
|
Marketing
Whenever we engage in marketing, we will
provide you with choices regarding certain personal data uses,
whenever we are required to do so.
We may use your Identity, Contact, Technical,
Usage and Profile Data to form a view on what we think you may want
or need, or what may be of interest to you. This is how we decide
which products, services and offers may be relevant for you (we call
this marketing).
You will receive marketing communications from
us if you have requested information from us or purchased goods or
services from us and you have not opted out of receiving that
marketing.
Opting out
You can ask us to stop sending you marketing
messages at any time by contacting us at any time.
Where you opt out of receiving these marketing
messages, this will not apply to personal data provided to us as a
result of [a product/service purchase, warranty registration,
product/service experience or other transactions].
Cookies
You can set your browser to refuse all or some
browser cookies, or to alert you when websites set or access cookies.
If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly. For more
information about the cookies we use, please visit our separate
cookie policy.
Change of purpose
We will only use your personal data for the
purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is
compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us.
If we need to use your personal data for an
unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your personal
data without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with the
parties set out below for the purposes set out in the table above.
External Third Parties as set out in the
Glossary.
Third parties to whom we may choose to sell,
transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may
use your personal data in the same way as set out in this privacy
policy.
We require all third parties to respect the
security of your personal data and to treat it in accordance with the
law. We do not allow our third-party service providers to use your
personal data for their own purposes and only permit them to process
your personal data for specified purposes and in accordance with our
instructions.
International transfers
We do not transfer your personal data outside
the European Economic Area (EEA).
Data security
We have put in place appropriate security
measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered or disclosed. In
addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our
instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with
any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do
so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as
long as reasonably necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, regulatory,
tax, accounting or reporting requirements. We may retain your
personal data for a longer period in the event of a complaint or if
we reasonably believe there is a prospect of litigation in respect to
our relationship with you.
To determine the appropriate retention period
for personal data, we consider the amount, nature and sensitivity of
the personal data, the potential risk of harm from unauthorised use
or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes
through other means, and the applicable legal, regulatory, tax,
accounting or other requirements.
By law we must keep basic information about our
customers (including Contact, Identity, Financial and Transaction
Data) for six years after they cease being customers for tax
purposes.
In some circumstances you can ask us to delete
your data: see your
legal rights below for
further information.
Your legal rights
Under certain circumstances, you have rights
under data protection laws in relation to your personal data. Please
click on the links below to find out more about these rights:
If you wish to exercise any of the rights set
out above, please contact us.
No fee usually required
You will not have to pay a fee to access your
personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we could refuse to comply
with your request in these circumstances.
What we may need from you
We may need to request specific information
from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights).
This is a security measure to ensure that personal data is not
disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your
request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests
within one month. Occasionally it could take us longer than a month
if your request is particularly complex or you have made several
requests. In this case, we will notify you and keep you updated.
Glossary
LAWFUL BASIS
Legitimate Interest
means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance
any potential impact on you (both positive and negative) and your
rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our
interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific
activities by contacting us.
Performance of Contract
means processing your data where it is necessary for the performance
of a contract to which you are a party or to take steps at your
request before entering into such a contract.
Comply with a legal obligation
means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
THIRD PARTIES
Professional advisers including lawyers,
bankers, auditors and insurers based in the UK who provide
consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other
authorities based in the UK who require reporting of processing
activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to
your personal data (commonly known as a "data subject access
request"). This enables you to receive a copy of the personal
data we hold about you and to check that we are lawfully processing
it.
Request correction of
the personal data that we hold about you. This enables you to have
any incomplete or inaccurate data we hold about you corrected, though
we may need to verify the accuracy of the new data you provide to us.
Request erasure of
your personal data. This enables you to ask us to delete or remove
personal data where there is no good reason for us continuing to
process it. You also have the right to ask us to delete or remove
your personal data where you have successfully exercised your right
to object to processing (see below), where we may have processed your
information unlawfully or where we are required to erase your
personal data to comply with local law. Note, however, that we may
not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable,
at the time of your request.
Email us on info@mywaytogo.io to request the deletion of your account data.
Object to processing of
your personal data where we are relying on a legitimate interest (or
those of a third party) and there is something about your particular
situation which makes you want to object to processing on this ground
as you feel it impacts on your fundamental rights and freedoms. You
also have the right to object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request restriction of processing of
your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios:
If you want us to establish the data's
accuracy.
Where our use of the data is unlawful, but you
do not want us to erase it.
Where you need us to hold the data even if we
no longer require it as you need it to establish, exercise or defend
legal claims.
You have objected to our use of your data, but
we need to verify whether we have overriding legitimate grounds to
use it.
Withdraw consent at any time where
we are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We
will advise you if this is the case at the time you withdraw your
consent.
